Stage 4 – Last Public Consultations!

TELL EDF YOUR SIZEWELL CONCERNS

Overview:

Construction will damage the things that make this part of Suffolk so special; peace, tranquility and dark night skies. Visitors will be driven away by eyesores, closed footpaths and beaches, disruption, noise and pollution, hurting £210m in annual tourism to the Area of Outstanding Natural Beauty.

The build will threaten some of the most biodiverse habitats in the UK and Heritage Coast, including two Sites of Special Scientific Interest and Minsmere Reserve – a national treasure. It will be impossible to recover from the loss of habitats that host rare birds, animals and plants. The RSPB believes that “Sizewell is not a suitable location for a new nuclear power station”.

The project is enormous – too big for the setting and land available. The Government considers that a single new nuclear power station should occupy 30 hectares (based on Sizewell B). Sizewell C & D are squeezed into 32 hectares, which is only available if Sizewell B facilities are relocated, resulting in further damage to the AONB. Hinkley Point C (HPC) in Somerset occupies 45 hectares.

EDF is insisting on a destructive new Link Road parallel with the B1122 which will have no long-term use, instead of the locally preferred ‘D2/W’ route that was originally proposed for Sizewell B.

EDF refuses to change its plans for a 2,400 bed multi-storey campus at Eastbridge, ignoring vigorous opposition from local people, the County Council and our MP.

EDF has yet to persuade County and District Councils that the benefits will outweigh the impacts. EDF figures show that 64% of workers – 3,585 of 5,600 at peak – will not be local.

Environmental Impacts:

What’s New at Stage 4? Not much. Sites for Marsh harrier mitigation will not compensate for habitat that will be lost. EDF is consulting on adding a 5th pylon with a 25% height reduction compared to 4.

EDF’s plans will cut the Area of Outstanding Natural Beauty in half for at least a decade, and threaten to compromise the purposes of the AONB designation itself.

The Environment Agency has, in its Stage 3 response, robustly criticised the lack and poor quality of preliminary environmental information (PEI) provided by EDF, with too much work unreported or even started, meaning consultees are unable to properly assess the acceptability of proposals. Stage 4 provides little, if any, additional information to answer the Agency’s criticisms.

Compensatory habitats must be in place before construction, at least equivalent to those lost.

EDF has not “woken up” to the fact that development projects need to provide ecological and diversity gain based on the 25 Year Environment Plan.

Insufficient evaluation of coastal effects both north and south has been made available.

When quarry pits are refilled with excavated peat and other materials, EDF has recognised the potential for pollution but is not proposing any mitigation or monitoring.

The construction laydown areas, accommodation site, spoil heaps, quarries, haul roads and causeway crossing of the SSSI will damage the fragile hydrology of the Minsmere Levels, Sizewell Marsh and affect the Minsmere Sluice. Alterations in the management of water run-off could make sensitive ecosystems wetter or drier, while the causeway crossing will impede the drainage of Sizewell Marsh SSSI habitat.

The proposed rock armour defence of the Sizewell C & D platform and Beach Landing Facility is inadequate, stopping above the low water line when it should go below it.

Spoil heaps, up to the height of a 10-storey building, could cause significant dust pollution to the AONB, Minsmere Levels and Sizewell Marsh and also affect human health.

EDF introduced 4 enormous pylons (65m & 48m) at Stage 3 due to insufficient space to install cabling underground as promised previously. Options at Stage 4 are for five pylons with a 25% reduction in height, or four pylons with only three reduced in height. All will impact the AONB.

EDF admits its ‘Rail-led’ strategy is uncertain. At peak up to 700 HGVs, 700 LGVs, 650 buses and thousands of Sizewell C-related cars would use the B1122 through Yoxford and Middleton Moor, with a bypass of Theberton.

The Theberton bypass affects too many residents and still places unfair congestion, noise, pollution, vibration damage and accidents on residents and visitors. Our groups and residents have never advocated bypasses around B1122 villages.

EDF’s Sizewell Link Road from the A12 (built under the ‘Integrated’ or ‘Road-Led’ strategies) runs too close to villages, homes and listed buildings, potentially operating 24/7. It is a poor choice of route requiring substantial embankments, cuttings, road and footpath closures, breaking up communities and making farms unviable. Parallel to the B1122, it will be of no use once the power station is built. EDF is now considering digging up this road afterwards. Far better to build a road with real legacy for Leiston and least impact on residents such as D2/W.

Sizewell C & D need a proper, low-impact Relief Road, similar to ‘D2’ or EDF’s route W, built before main construction starts. D2 is a more strategic route, serving multiple Energy Projects and providing a strong legacy for Leiston and Saxmundham.

In EDF’s ‘Early Years’, up to 600 HGVs/day, plus hundreds of vehicles for other Energy Projects would use the current B1122, before any new roads or Park & Rides are ready.

Even with a new roundabout Yoxford will become a congestion and pollution blackspot.

No direct figures are provided for the site entrance roundabout but we estimate SZC traffic will be responsible for doubling the total traffic on the B1122 outside Leiston; with over 6,800 SZC-related lorries, buses, vans and cars on a “busiest day” and just under 6,500 on a “typical day”.

Around HPC, rat-running on country lanes and congestion in villages from flyparking by workers have become serious problems. EDF are doing nothing to prevent this here.

We recommend opposing all road and footpath closures across EDF’s associated development.

EDF’s source of aggregates is unknown, but could be the same as HPC, from SW England. EDF’s Freight management facility, the Orwell Bridge and (new) roundabouts on the A12 will all affect traffic. We recommend highlighting accident blackspots and traffic pinch-points you know of.

Accommodation:

What’s new? Nothing! EDF refuses to change accommodation plans despite widespread criticism, proposing a new ‘town’ for 2,400 workers, of 3-4 storey blocks with car parks and leisure facilities, on a greenfield site close to Minsmere and next to Eastbridge, a hamlet of 50 people. EDF keeps repeating that split sites are not popular with contractors – do paid contractors’ views count more than ours?

Using the campus is not compulsory and is single occupancy; workers must go out to socialise with anyone other than immediate colleagues or to use sports facilities.

EDF refuses to consider housing workers in urban areas with suitable social infrastructure and legacy potential, similar its approach at HPC with 500 beds onsite and 1,000 in Bridgwater, where the site has been prepared for new housing afterwards.

The campus will bring noise, air and light pollution, a massive increase in traffic, and the potential for anti-social behaviour. This will affect our health and wellbeing and place an unfair burden on Leiston, Eastbridge, Theberton and Minsmere.

People and Economy

What’s New? Very little. To test its planning, EDF is modelling on a maximum workforce of 7,900.

EDF is aiming for 20% cost savings at Sizewell, in part by using the HPC supply chain. EDF must state how this will affect tourism and the promised economic and employment benefits for the local area.

EDF is providing 3,000 beds but has learned from HPC that workers do not wish to commute 90 minutes, meaning there will be even more home rentals. EDF expects a further 585 workers to occupy other accommodation, meaning 64% of workers will not be local. If peak workforce rose to the modelled maximum of 7,900, EDF predicts 5,875 (75%) would not be local, with 2,875 additional beds needed from local rental housing supply.

Home rental costs at HPC increased 18% in 2018, say the BBC. In August 2019, various media reported increased pressure on the housing market, and a need for extra caravan spaces at HPC.

EDF hasn’t yet conducted many vital studies including Health and Community. The project must not reduce locals’ access to emergency services and healthcare.

Comments on EDF’s Consultation Process

Sizewell C & D is a Nationally Significant Infrastructure Project. Despite 4 rounds of consultations, the substance has been inadequate for a project of this scale. From the responses of statutory consultees – Environment Agency, County, District and local councils – it is clear that EDF has not provided sufficient PEI or addressed the concerns of local people and significant NGOs, such as RSPB, AONB and SWT. EDF says it is holding this fourth stage of consultations because stakeholders asked for it, but there are almost no changes that address our concerns.

There is very little mention of cumulative environmental, traffic, social and other impacts, and no assessment of the combined impact of overlapping Energy Projects.

Throughout the consultations, EDF has failed to present adequate comparisons e.g. between potential accommodation sites or relief road routes. This denies the public the ability to respond in an informed manner. Important studies are being withheld until Development Consent.

EDF did not bother to come to some of the most affected communities at Stage 4 – including Theberton & Eastbridge and Middleton – to explain why it had not addressed many concerns.

Other Issues:

EDF says Sizewell C & D can help the government’s net-zero by 2050 plan. The Committee on Climate Change says that renewables could fill the gap more quickly and cheaply than nuclear. A government Energy White Paper is expected imminently and a new National Policy Statement to replace EN-6 is required before any development can be approved.

Government is consulting – until 14 October – on a new nuclear finance model called the ‘Regulated Asset Base’ (RAB). EDF has suggested all UK energy customers pay £6/year to help finance Sizewell C. Any new finance model will require legislation. (See Take Action overleaf).

At least 6 other energy projects are planned for the area, to serve offshore wind farms. Construction will overlap with Sizewell – but legally the government is unable to take account of the combined effects! EDF’s EIAs must assess the impacts of all projects together.

Spent fuel will be kept onsite until at least 2135; no long-term nuclear waste facility is available.

EDF’s partner, China General Nuclear (a Chinese state company) was recently blacklisted by the US over security concerns. China uses financial investment to wield political influence over nations.

HOW TO RESPOND

The deadline for Stage 4 Consultations responses is 27 September. Write to EDF, Freepost SZC Consultation, or send emails to info@sizewellc.co.uk. You can respond as often and in as many ways as you like. EDF aims to apply for Planning Consent in 2020.

We strongly recommend resending your Stage 3 response, highlighting where EDF has failed to address your concerns as well as expressing new concerns. Letters or emails are highly preferable to responding via EDF’s questionnaire as this is too narrow. If you wish to suggest ‘improvements’ to proposals you oppose, we recommend using phrases such as “Although I oppose [X], the following changes would make it less bad”, to ensure EDF does not misrepresent your ideas as supporting their plans.

Join the RSPB’s ‘Love Minsmere’ Festival on 15 September, http://bit.ly/LoveMinsmere to register. We’d love our community of supporters to stand together when making the heart, so please make your way to the bottom of the hill (where the pointy bit will be) in good time for 1pm. RSPB has requested we wear white or blue, the colours of their Love Minsmere logo.